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Flood Insurance Rate Maps and Flood Insurance Studies: From Preliminary to Effective
Lisa Messano
After FEMA’s release of a preliminary Flood Insurance Rate Map (FIRM), the following steps must occur before the new map can become effective. While the post-preliminary processing is underway, the current FIRM remains in effect. To distinguish the preliminary FIRM panels from the currently effective panels, the letter suffix at the end of the panel identification number advances by one letter. For example, an effective panel numbered 12345C7890A is replaced by preliminary panel 12345C7890B when the preliminary panel becomes effective.
The graphic below shows a general timeline for this process.

Collect Initial Comments on Preliminary FIRM and Report
FEMA holds meetings to present the maps first to local community officials at the Consultation Coordination Officer (CCO)/Preliminary FIRM Meeting. Any changes in flood risk will be explained and participants will have an opportunity to provide feedback on the products at the meeting and during a 30-day comment period that follows the meeting. 
FEMA also prepares a Risk MAP Flood Risk Product, Changes Since Last FIRM, often used to visually communicate changes to Special Flood Hazard Areas (SFHAs) from the currently effective FIRM panels to the Preliminary FIRM panels. An example of this product can be viewed for Marin County as part of the Open Pacific Coast Study on the Region IX website here
CCO meeting attendees typically ask questions about the FIRMs, flood insurance requirements following the map changes, and floodplain management requirements. A fact sheet that explains what property owners need to know regarding map changes and flood insurance is available on FEMA’s website here.  When FEMA issues updated flood maps, the results of current Letters of Map Change (LOMCs) may be impacted. FEMA issues a Summary of Map Actions (SOMA) and Revalidation Letter during the map revision process to assist communities in understanding these impacts.  The SOMA and Revalidation Letter are also discussed at the CCO meeting. The Understanding FEMA’s Summary of Map Actions and Revalidation Letter fact sheet provides further details. (Also read The Summary of Map Actions (SOMA) Report: SOMAs Deciphered in this issue of Coastal Beat.)
FIRM 90-Day Appeal Period
A few weeks after the CCO Meeting and the completion of a public notification process, primarily directed at local community officials, a 90-day appeal period for communities with new or updated flood hazards begins. During this period, community officials and the public (through their community officials) can submit technical data to revise the FIRM if they believe it is scientifically or technically incorrect. This includes additions or modification of any Base Flood Elevations (BFEs) or SFHA boundaries or zone designations. 
The term “comment” is used for any submittal that does not meet the strict definition of an appeal. Non-technical comments on other aspects of the preliminary FIRM such as road names and corporate limit changes are also accepted during this appeal period. Anyone can submit an appeal or comment; however, all submittals must be reviewed by the appropriate community official before FEMA reviews the information.
To be considered an appeal, a submittal must include data that show the proposed flood hazard information is technically incorrect and include the necessary revisions to the FIRM and/or FIS report.  The appeal must also be received during the statutory 90-day appeal period. Acceptable data could include alternative coastal analyses to support a change to BFEs or SFHA boundaries or more detailed or accurate topographic (elevation) data in support of flood hazard boundary changes. Revised flood zone boundaries and/or FIS report tables showing the resulting changes to the preliminary FIRM and FIS report must be provided in digital format. Supporting data must be certified by a registered Professional Engineer or Licensed Land Surveyor, as appropriate. More detail about types of data to submit for an appeal is available in FEMA’s Criteria for Appeals of Flood Insurance Rate Maps. Another helpful resource, “Appeals, Revisions, and Amendments to National Flood Insurance Program Maps: A Guide for Community Officials,” is available on FEMA’s website here.
Resolve Appeals and Finalize Map Products
FEMA will review all appeals and comments and will, if appropriate, make changes to the FIRM, based on the information submitted. If FEMA determines that appeal data is not technically superior to FEMA’s data, the appeal will be denied and the information on the preliminary FIRM will remain unchanged.  However, the designation of a submittal as an appeal provides specific appellant rights, including the opportunity for the affected community to have its data reviewed by a Scientific Review Panel (SRP). If the SRP decides in favor of FEMA, the preliminary FIRM will remain unchanged.  If the SRP decides in favor of the community, the community’s data will be used to issue a revised preliminary FIRM.
Due to map scale limitations, changes to individual lots or structures typically cannot be shown on the FIRM. Therefore, the appeals process typically cannot be used to remove an individual property/structure from the floodplain. Instead, FEMA has made available the Letter of Map Amendment (LOMA) process for property owners who believe their home or property has been inadvertently included in the floodplain. LOMAs officially change the zone designation on an effective FIRM, not a preliminary FIRM, so a LOMA must be submitted after the new FIRM is finalized. More information about the process and required information can be obtained at FEMA’s LOMA webpage.
After resolving all appeals, FEMA finalizes the FIRM panels. A Letter of Final Determination (LFD) establishing the final flood elevations is sent to community officials for each affected community. The LFD starts a 6-month adoption and compliance period during which communities must adopt or amend their floodplain management regulations to reflect the changes in the FIRM. In some cases, communities may have to adopt additional floodplain management requirements if a new type of flood hazard data is provided, such as a flood zone designation that is not depicted on their currently effective FIRM.  Towards the latter part of the 6-month compliance period, the finalized preliminary PDFs and the preliminary DFIRM database are posted to the MSC website as future data and replace the effective data on the effective date noted in the LFD.
6-Month FIRM Adoption Period
The FIRM and FIS report become effective at the end of the six-month compliance period and will serve as the basis for determining flood insurance rates and purchase requirements as well as local building requirements codified in the community’s floodplain management regulations. 
Communities are encouraged to adopt the appropriate floodplain management regulations as soon as possible after the LFD is issued. The adopted regulations must be submitted to FEMA or the State, and be approved by FEMA thirty days prior to the effective date of the FIRM and FIS report. 
If communities are not considered compliant at LFD, FEMA will send two letters notifying the community that it must have approved floodplain management regulations in place before the date of the effective FIRM. The first letter is a reminder letter and is sent to the community 90 days before the effective date of the FIRM. The second letter is sent to the community 30 days before the effective date of the FIRM. If a community does not adopt new floodplain management regulations or amend its existing regulations before the effective date of the FIRM and FIS report, the community will be suspended from the NFIP. 
If a community is suspended from the NFIP, it may regain its eligibility in the NFIP by enacting the floodplain management measures established in 44 CFR Section 60.3 of the NFIP regulations. If development occurs in the community during suspension that does not meet the minimum NFIP requirements, the community will need to take actions to reduce the increased flood hazard prior to reinstatement. You can contact the FEMA Regional Office or your State NFIP Coordinating Agency for assistance on the specific requirements for your community. 
More information about what goes into a flood map is available in this infographic on FEMA’s website.

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